Having said all this let me state for the record that the D.C.
Society of Independent Accountants (DCSIA) and I do, in fact, thoroughly
agree with AICPA Vice President for Education Dr. Rick Elam, who
reported that a dozen studies by independent organizations over the past
20 or so years concluded that more education is needed by all
accountants. However, Dr. Elam also writes in his letter dated March 19,
1990, to the Executive Director of the N.J. State Board of Accountancy
and to the then President of the N.J. Society of CPAs "No, it s not
really necessary to increase the number of accounting hours to prepare a
CPA. The real element that's missing in most CPA's education
is a broad view of the world and the ability to communicate with all of
the different constituents that CPAs serve."

Dr. Elam goes on to say that the CPA examination is extremely
limited in what it can test and that there is absolutely no way it can
test all those important aspects of an individual's preparation
necessary to be a CPA. Simply stated, it seems to me that AICPA wants
the several states, and by extension the taxpayer and customers of CPAs,
to bear the enormous cost of culturally educating all of our CPAs.

IF the AICPA and NASBA truly want to improve the quality of public
accounting services and at the same time reduce the cost of these
services - there is a better solution. Mrs. Binetta Dolan, Chairperson,
Department of Business Administration, Georgian Court College writes in
a letter to the Executive Director of the N.J. Association of Public
Accountants: "The Georgian Court College, Department of Business
Administration, Accounting and Economics, supports (the N.J.) Assembly
Bill A-3429 which will provide an alternative for students to obtain a
license to practice public accounting without needing a CPA
certificate."

This concept is further delineated by William H. Sager, Esq., who,
as Legal Counsel for the National Society of Public Accountants, in
testimony before the California Legislative Committee on Governmental
Efficiency and Consumer Protection supported the establishing of an
additional class of licensed accountants - a class of registered
accountants to be licensed and regulated by the State Board of
Accountancy to perform all accounting functions except the audit attest function, after each such accountant will have passed legislative
qualification test.

These registered accountants will be equipped educationally and
culturally to serve the small-business sector of our economy. I am
referring to the "Mom and Pop" business, the thousands of
gasoline serving stations, the hundreds of small associations, the
corner pharmacies, the various and sundry sole proprietorships, the
multitudes of small size partnerships, the unlimited number of small
corporations, all of which can be served by these registered accountants
without the "overkill" in cost of the highly trained master
CPAs.

Further, the registered accountants presently unlicensed are at
this exact moment serving the public as accountants. The problem is that
being unlicensed, these accountants are not regulated. Yet, one of the
basic reasons for the 150 Semester Hour Educational Rule, a reason
supported by both the AICPA and Dr. Nathan T. Garrett, Vice president of
the National Accountancy, is to "protect Board of Accountancy, is
to "protect the public!"

I submit that if America's certified public accountants and
the proposed master CPAs with all their superior education need to be
regulated in order to "protect the public," the unlicensed
accountants (and there are thousands of them) also need to be regulated
if, indeed, we would protect the public.

I further submit that you cannot regulate these thousands of
accountants without licensing them.

In conclusion, I assure the AICPA that DCSIA and I am sure all of
the other associations represented here today will be most pleased to
work with AICPA and with NASBA to maintain the quality of public
accounting services and to help educate America's accountants so
that accountancy will continue to be the honorable profession as we know
it, an honorable profession of which all Americans are indeed proud.

Clyde Larmer is a former member of the DC Board of Accountancy having
served for eight years. He is a longtime member of NSPA and a past
president of the DC Society of Independent Accountants.

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